PRA publishes PS3/24 finalising Solvency II reporting and disclosure changes

The Prudential Regulation Authority (PRA) has finalised the second phase of its Solvency II reporting and disclosure reforms with Policy Statement PS3/24, published on 29 February 2024. PS3/24, issued alongside PS2/24, sets out part of the final Solvency UK rule set and confirms a broad reshaping of quantitative and narrative reporting for solo firms, groups and third‑country branches.

Scope and process of the phase 2 package

PS3/24 covers the PRA’s phase 2 review of Solvency II reporting and disclosure and follows Consultation Paper CP14/22 on reporting phase 2. The PRA states that PS3/24 incorporates feedback from CP14/22, which received 18 responses, and uses that feedback to refine both the scale and focus of the final reporting package. PS3/24 and PS2/24, published on 28 and 29 February respectively, together set out final Solvency UK rules, confirming the PRA’s move from the EU Solvency II regime to a domestic rulebook.

Structural changes to quantitative reporting templates

The PRA’s final policy removes 55 reporting templates from the Solvency II reporting package. In addition, the PRA deletes one further template on risk concentration with the stated aim of further reducing the existing reporting burden for insurance groups.

Alongside these deletions, PS3/24 introduces three new templates focused on excess capital generation, cyber risk underwriting and non‑life product obligations. The PRA also states that it has made changes to streamline and improve the comprehensibility of templates covering reporting on group SCR, premiums, claims and expenses, as well as cross‑border activity.

PS3/24 introduces activity‑based reporting thresholds for certain reporting and disclosure templates, moving away from a purely size‑based approach for some returns. The PRA notes that these thresholds are introduced and amended across selected templates to better align reporting with the nature and scale of firms’ activities.

Narrative reporting and RSR changes

Within the narrative reporting framework, PS3/24 proposes the removal of the requirement for all Solvency II firms, including third‑country branches, to submit the Regular Supervisory Report (RSR). This change affects both solo firms and branches that were previously required to produce the RSR under the Solvency II regime.

The PRA also simplifies reporting requirements on the transitional measure on technical provisions (TMTP), stating that PS3/24 includes a simplification of TMTP reporting. These TMTP changes sit within the broader effort in PS3/24 to reduce complexity in the reporting package while retaining information the PRA considers necessary for supervision. The PRA states that these new requirements are intended to give it better visibility of the overall financial position of the overseas insurer behind the UK branch.

At the same time, the PRA’s revisions in PS3/24 remove expectations for third‑country branches to report a range of templates relevant to branch capital requirements, the branch risk margin and the localisation of assets to cover the branch SCR. This represents a shift in branch reporting from detailed branch‑level capital and asset localisation templates towards more entity‑level solvency information.

Internal model and SCR analysis reporting

PS3/24 introduces new reporting requirements on the change in internally modelled SCR through the year, described as an “Analysis of change”. This new requirement is aimed at providing the PRA with a structured breakdown of movements in internal model SCR between reporting dates.

The PRA also states that policy changes to reporting on group SCR, premiums, claims and expenses result in further streamlined and more comprehensible templates, following feedback on CP14/22. These adjustments affect how groups present SCR and performance information across their UK and cross‑border activities.

Implementation, taxonomy and transition support

The PRA states that the changes to systems and controls set out in PS3/24 will need to be implemented by insurers by 31 December. This implementation date aligns with the effective date for the PRA’s wider Solvency II Review rule package.

A single taxonomy package for the new reporting requirements was scheduled for publication in Q2 2024, providing the technical specifications for firms’ reporting systems. To support transition, the PRA has also held industry roundtables to help firms prepare for the new reporting requirements.

The PRA intends to publish its final package of rules relating to the Solvency II Review, including the final Policy Statement for CP5/24 on restatement of assimilated law, in mid‑November 2024, with those rules coming into effect on 31 December. This timetable means PS3/24’s reporting and disclosure changes sit within a broader Solvency UK rule set that is due to be fully effective from the end of 2024.

--- Sources: https://www.bankofengland.co.uk/prudential-regulation/publication/2024/february/review-of-solvency-ii-reporting-and-disclosure-phase-2 https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2024/05/pra-solvency-uk-policy-statements.pdf https://www.bankofengland.co.uk/prudential-regulation/publication/2024/february/review-of-solvency-ii-reporting-and-disclosure-phase-2-near-final-policy-statement